Rodriguez 238723 v. Thornell

CourtDistrict Court, D. Arizona
DecidedAugust 8, 2025
Docket2:24-cv-00623
StatusUnknown

This text of Rodriguez 238723 v. Thornell (Rodriguez 238723 v. Thornell) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rodriguez 238723 v. Thornell, (D. Ariz. 2025).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Jorge Carlos Rodriguez, No. CV-24-00623-PHX-KML

10 Petitioner, ORDER

11 v.

12 Ryan Thornell, et al.,

13 Respondents. 14 15 Petitioner Jorge Carlos Rodriguez was convicted in state court of sex crimes 16 involving children and sentenced to lengthy terms of imprisonment. Rodriguez’s federal 17 petition alleges four claims, mostly based on the state trial court requiring he wear a stun- 18 belt and leg brace during trial. Magistrate Judge James F. Metcalf issued a Report and 19 Recommendation (“R&R”) recommending two claims be denied on their merits and two 20 claims be dismissed as procedurally defaulted. (Doc. 22.) Rodriguez filed objections but 21 the R&R’s recommended result is correct and Rodriguez’s petition is denied. 22 I. Background 23 Neither party objects to the R&R’s factual background and it is adopted. In brief, 24 Rodriguez was charged with multiple sex crimes and proceeded to trial. The trial court 25 required Rodriguez wear a stun-belt and leg brace during trial but “did not hold an 26 evidentiary hearing or make an independent determination for the need for restraints” 27 before doing so. (Doc. 15-3 at 119.) After Rodriguez was convicted of multiple counts he 28 pursued a direct appeal. Most of his arguments were rejected during that appeal but the 1 Arizona Court of Appeals remanded for “the trial court to hold a hearing to evaluate the 2 need for the restraints and whether they interfered with [Rodriguez’s] right to a fair trial.” 3 (Doc. 15-3 at 119.) 4 On remand the trial court conducted an evidentiary hearing and issued findings of 5 fact. In those findings, the court concluded use of the stun-belt and leg brace had been 6 appropriate based on the length of sentences Rodriguez was facing, his criminal history, 7 and the configuration of the courtroom. (Doc. 15-5 at 359-60.) The trial court also stated 8 “[t]here [was] no evidence the stun-belt . . . and leg brace . . . were visible to the jury.” 9 (Doc. 15-5 at 359.) Rodriguez again appealed but the Arizona Court of Appeals affirmed, 10 concluding Rodriguez had not shown the stun-belt and leg brace denied him a fair trial. 11 (Doc. 15-5 at 456.) 12 After his direct appeals concluded, Rodriguez sought post-conviction relief in state 13 court. The trial court denied relief and Rodriguez did not file a petition for review with the 14 Arizona Court of Appeals. Rodriguez claims he lacked access to the record when preparing 15 both his initial petition for post-conviction relief and his petition for review. The R&R 16 points out Rodriguez’s arguments regarding access to the record appear to be focused on 17 obstacles Rodriguez faced in filing his petition in the trial court, but it is Rodriguez’s failure 18 to file a petition for review with the court of appeals that is the possible basis for concluding 19 some claims were procedurally defaulted. (Doc. 22 at 12.) 20 II. Analysis 21 The R&R construed Rodriguez’s federal petition as asserting four claims. The first 22 two claims involve the stun-belt and leg brace (collectively, “restraints”); the third and 23 fourth claims involve ineffective assistance of trial and appellate counsel (“IAC claims”). 24 All the claims have significant overlap as even the IAC claims primarily raise counsel’s 25 failures involving the restraints (although Ground Four also cites additional failures). The 26 R&R concludes Rodriguez’s first two claims were exhausted and should be reviewed on 27 their merits, but the IAC claims were not exhausted and there is no basis to excuse that 28 failure. Rodriguez filed objections and respondents filed a reply. (Doc. 27, 28.) 1 A. Exhausted Claims 2 In rejecting the merits of Rodriguez’s first two claims based on the use of restraints, 3 the R&R reasons the state court made a factual finding that the restraints had not been 4 visible to the jurors, and that factual finding was not unreasonable. (Doc. 22 at 14.) 5 Accepting that the restraints were not visible, the R&R concludes there is no clearly 6 established Supreme Court authority that prohibits “post-trial findings of justification” of 7 the need for restraints.1 (Doc. 22 at 18.) Rodriguez’s objections focus on his belief that “the 8 restraints may have been visible to, or perceived by, the jurors.” (Doc. 27 at 6.) And based 9 on that possibility, Rodriguez appears to argue the trial court’s failure to make findings of 10 justification before trial violated his federal constitutional rights. 11 A federal court must “accord the state trial court substantial deference” when 12 reviewing factual findings. Brumfield v. Cain, 576 U.S. 305, 314 (2015). “If [r]easonable 13 minds reviewing the record might disagree about the finding in question,” a federal court 14 must accept the state court’s finding. Id. (simplified). The state trial court in this case found 15 the restraints were not visible during Rodriguez’s trial. (Doc. 15-5 at 359.) Rodriguez’s 16 objections cite arguably contradictory evidence presented at the evidentiary hearing (Doc. 17 27 at 6), but the trial court rejected that evidence (Doc. 15-5 at 359) and it had a sufficient 18 basis to do so. During the evidentiary hearing regarding the use of restraints, Rodriguez’s 19 counsel testified he would have alerted the court if he believed a juror had learned of the 20 restraints. (Doc. 3-1 at 40.) And it was undisputed that during trial Rodriguez had taken the 21 witness stand outside the presence of the jury. Relying on these facts and others, the state 22 trial court concluded the restraints had not been visible. This court accepts that finding, as 23 it must. See Brown v. Poole, 337 F.3d 1155, 1160 n.2 (9th Cir. 2003) (requiring deference 24 to “all factual findings of the state court that are reasonable in light of the evidence

25 1 The R&R determines that if Rodriguez’s restraints had been visible, “the Arizona Court of Appeals’ reliance on the trial court’s post-trial findings would have been contrary to the 26 clearly established law” as set forth by the United States Supreme Court. (Doc. 22 at 18.) But even assuming the restraints had been visible and it was impermissible to rely on post- 27 trial findings justifying those restraints, the issue would still be subject to harmless error review. Larson v. Palmateer, 515 F.3d 1057, 1064 (9th Cir. 2008). Rodriguez would be 28 entitled to relief only on showing even visible restraints “had a substantial and injurious effect or influence in determining the jury’s verdict.” Id. (simplified). 1 presented in the state court proceedings.”) (quotation omitted). 2 In light of the state court’s factual finding, the issue is whether the use of non-visible 3 restraints violated Rodriguez’s clearly-established constitutional rights. To be entitled to 4 relief, Rodriguez would need to establish the state court’s determination was “contrary to, 5 or involved an unreasonable application of, clearly established Federal law, as determined 6 by the Supreme Court of the United States.” 28 U.S.C. § 2254(d)(1). The Supreme Court 7 has not addressed when, if ever, the use of non-visible restraints might violate a defendant’s 8 due process rights. See Shirley v. Tegels, 61 F.4th 542, 546 (7th Cir. 2023) (“No Supreme 9 Court precedent has squarely addressed whether placing a criminal defendant in hidden 10 physical restraints unconstitutionally inhibits that defendant’s ability to present a complete 11 defense at trial.”).

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Related

Charles Roberts v. Arvon J. Arave, Jim T. Jones
847 F.2d 528 (Ninth Circuit, 1988)
Liza Brown v. Susan E. Poole
337 F.3d 1155 (Ninth Circuit, 2003)
Larson v. Palmateer
515 F.3d 1057 (Ninth Circuit, 2008)
Brumfield v. Cain
576 U.S. 305 (Supreme Court, 2015)
Richard Shirley, Jr. v. Lizzie Tegels
61 F.4th 542 (Seventh Circuit, 2023)

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Rodriguez 238723 v. Thornell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rodriguez-238723-v-thornell-azd-2025.